ML20115A658

Comments on Proposed Changes to SALP Program

ML20115A658
Person / Time
Site:	Pilgrim
Issue date:	10/05/1992
From:	Richard Anderson BOSTON EDISON CO.
To:	NRC
References
FRN-57FR39249 57FR39249, 92-115, GL-92-05, GL-92-5, NUDOCS 9210150022
Download: ML20115A658 (3)

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BOSTO EDISON OFFICE OF M 0lSTRAT!n

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72 OCT -9 A10:52 October 5, 1992 R::y A. AnArson BEco Ltr 92-115 Senior Vice President -- Nuclear Chief, Rules and Directives Review Branch U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docket No. 50-293 License No. DPR-35

Subject:

COMMENTS ON PROPOSED CHANGES TO SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) PROGRAM

Dear Sir:

Enclosed for your review and consideration is sustcn Edison Company's written comments to Generic Letter 92-05 regarding the NRC's proposed changes to the SALP

Program, o cob 4

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R. A. Anderson RLC/bal/ Comments Enclosure cc:

U.S. Nuclear Regulatory Commission ATTN: Document. Control Desk Washington, D.C. 20555 Sr. NRC Resident Inspector - Pilgrim Station 9210150022 921005 bSSC59FR39249PDR

h ENCLOSURE COMMENTS ON PROPOSED CHANGES TO SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALPl PROGRAM Boston Edison Company-Docket No. 50-293 Pilgrim Nuclear Power Station License No. DPR-35 Boston Edison Company (BEco) has reviewed the draft of Directive 8.6 containing the-proposed changes to the Systematic Assessment of Licensee Performance (SALP)

Program. Although several desirable changes were identified during our review other changes appear to be less than desirable.

Based on our review, the following comments are submitted:

1.

Consideration should be given to deleting numerical grades for SALP functional categories.

The assignment of grades actually serves more of a political function than a communication function between the NRC and Licensees.

SALP Reports can still communicate a performance assessment message to licensees and the public without a numerical grade.

Numerical grades tend to:

Focus more on the grade and less on the issues that lead to the grade.

Create potential inconsistencies between regions and within regions.

Cause licensee resources to be diverted to areas that may not be appropriate due to the public nature of the grades.

Provide a mechanism for state regulators and financial institutions to force utilities into agreements that can focus resources and decisions in a manner not always consistent with the safety objective of SALP.

Lead to public misunderstanding of licensee performance due to lack of understanding of the SALP grade meaning.

For these reasons, it is recommended grades be deleted in favor of the SALP report written comments and dialogue.

2.

The combining of Rao alogical Controls, Emergency Preparedness, and Security into one functional area is considered to be an undesirable change we believe will reduce the effectiveness of the SALP program.

The SALP program effectiveness would be impacted by:

Reduced focus and attention to affected functional areas.

Lost sense of ownership of iffected functional areas.

Decreased communications and dialogue between licensee and regulator for the affected functional areas.

In addition to the above:

Existing defined SALP functional areas provide a more desirable distribution and are more helpful to licensees.

Public understanding and interpretation of SALP results are better served by existing assigned functional areas.

.i 3.

As a possible alternative to combining functional areas, weighted values could be assigned to each functional area based on the area's size and significance.

For example,- Emergency Preparedness could have a assigned value-of 0 while Plant Operations could have an assigned value of 1.0.

From-these values, one can clearly see that having a SALP 1 in Operations has more significance than receiving a SALP l in Emergency. Preparedness.

4.

The distribution of the Safety Assessment and Quality Verification 'unctional area-into the-remaining functional areas is viewed by Boston Edison Company as a favorable change.

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